Paraguay Corporate Income Tax

General reference only. This skill is general tax/accounting reference material for AI-assisted workflows. It has not been reviewed for any specific person's facts, documents, elections, deadlines, residency, filing status, or local procedures. Do not rely on it to file, pay, amend, or take a tax position without review by a qualified professional in the relevant jurisdiction.

The law is Ley N° 6380/2019 "De Modernización y Simplificación del Sistema Tributario Nacional", Libro I, Título I (arts. 1 to 39), read in the text published by the Biblioteca y Archivo Central del Congreso Nacional (BACN). The regulation is the Anexo to Decreto N° 3182/2019, read in the copy published by the Dirección Nacional de Ingresos Tributarios (DNIT, which replaced the Subsecretaría de Estado de Tributación under Ley N° 7143/2023). Article 83 of that Anexo (advance payments) was replaced by Decreto N° 7402/2022. The DNIT list of tax laws was checked on 11 November 2026: the only later law that changes the text of Ley 6380 is Ley N° 7067/2023, which touches the IVA exemptions in art. 100 and nothing in the IRE. Ley N° 7548/2025 (new investment incentive regime) and Ley N° 7547/2025 (maquila) refer to Ley 6380 without amending the IRE articles. Amounts are in guaraníes (G). The fiscal year (ejercicio fiscal) is the calendar year (art. 7), so tax year 2026 is the year to 31 December 2026, with its return due in April 2027.

Who this applies to

• IRE taxpayers (art. 2): sole-owner businesses (empresas unipersonales, including EIRL) and their undivided estates; sociedades simples, S.A., S.R.L., sociedades en comandita and de capital e industria; consortia for a public work (members jointly liable); associations, corporations, foundations, cooperatives and mutuals; transparent legal structures; public enterprises and mixed-economy companies; branches, agencies and permanent establishments of foreign persons; and any other private entity, with or without legal personality.
• What is taxed (arts. 1 and 6): Paraguayan-source income from every economic activity (primary, secondary, tertiary, including agriculture), plus income from assets and rights and any increase in net worth. Income taxed under the personal income tax (IRP) is excluded. Paraguayan source includes, among others, technical assistance and services performed in Paraguay, interest and returns on deposits abroad and dividends from foreign entities received by a resident investor, and derivatives where the investor is resident. Income from activities abroad not listed in art. 6 is also Paraguayan source unless the taxpayer paid a foreign income tax on it at a rate equal to or above 10% (art. 6, last paragraph).
• A sole-owner business (art. 3) is an organised, habitual unit of a person combining labour and capital, with capital predominant, in the 17 activities listed (agriculture and extraction, trade, renting, pawnbroking, repairs, transport, parking, security, shows, restaurants and hotels, travel agencies, funeral services, laundry, hairdressing, advertising, construction, carpentry/plumbing/electrics). Personal services without that structure belong to the IRP: see paraguay-income-tax.
• Transparent legal structures (art. 4): trusts under Ley 921/1996, Fondos Patrimoniales de Inversión under Ley 5452/2015 and risk-sharing joint ventures are fiscally neutral; their income and costs are taxed in the hands of each beneficiary.
• Residence (art. 5): entities formed under Paraguayan law, and foreign entities that set up domicile in Paraguay from their registration in the Public Registry.
• Exempt income (art. 25): interest on public debt; education services by recognised entities; dividends received that bear IDU; cooperative surpluses from operations with members; international freight for exports by the carrier issuing the transport document; interest from Banco Central del Paraguay instruments; stock-exchange returns and gains on regulated securities; Fondo Patrimonial de Inversión returns. Exempt persons include foreign official bodies (reciprocity), religious entities (on worship income), non-profit public-benefit entities and political parties, unions and business associations (on their non-business income; the exemption is lost for the listed activities carried on permanently as a business), and social-security entities.

When to refer. Refer to a specialist for: banks and finance companies (Ley 861/1996 capital and provisions rules in art. 15.17), insurers, maquila (Ley 7547/2025), projects under the investment incentive regime of Ley 7548/2025, free-zone users, reorganisations, agricultural small-producer special regimes (Decreto 3276/2020 and Decreto 3182 arts. 93 to 98), and the transfer pricing study itself. Individuals: paraguay-income-tax. IVA returns: paraguay-iva. Employer contributions: paraguay-social-contributions.

Rates, bands and thresholds

Quick answer: 10% of net income in the general regime and in SIMPLE; RESIMPLE pays a fixed monthly amount instead. The regime is chosen by the gross income of the previous fiscal year.

Item	Rate or amount	Year	Source
IRE rate on net income (Ley 6380 art. 21)	10%	2026	https://www.bacn.gov.py/leyes-paraguayas/9332/ley-n-6380-de-modernizacion-y-simplificacion-del-sistema-tributario-nacional
SIMPLE regime, sole-owner businesses and the art. 2.8 entities, prior-year accrued income up to (art. 26)	G 2,000,000,000; optional	2026	same
SIMPLE net income (art. 26)	The lower of real net income (documented income less directly related outgoings, including goods, inputs, furniture, equipment and works on the premises) and 30% of gross annual billing; taxed at 10%; a negative result is not carried forward	2026	same
RESIMPLE, sole-owner businesses only, prior-year gross income up to (art. 27)	G 80,000,000; not available to a business that must keep full accounts under Ley 1034/1983 (Decreto 3182 art. 81), nor to importers and exporters (art. 28)	2026	same
RESIMPLE monthly amount, prior-year gross income up to G 20,000,000 (art. 27)	G 20,000 a month	2026	same
RESIMPLE, G 20,000,001 to G 40,000,000 (art. 27)	G 40,000 a month	2026	same
RESIMPLE, G 40,000,001 to G 60,000,000 (art. 27)	G 60,000 a month	2026	same
RESIMPLE, G 60,000,001 to G 80,000,000 (art. 27)	G 80,000 a month	2026	same
Presumed net income, forestry and sale of urban or rural real estate held as fixed assets, optional (art. 19)	30% of the sale value, no proof to the contrary; then 10%	2026	same
Presumed net income, international telecoms and data services from Paraguay, container hire, international transport, optional and fixed for 5 years (art. 20)	30% of gross income; then 10%	2026	same
Loss carry-forward (art. 18)	Up to the 5 following fiscal years; each year capped at 20% of that year's net income	2026	same
Interest, royalties and technical assistance paid to partners, head office or related companies (art. 15.23)	Deductible only at market price or the BCP average deposit rate, tax paid on them, and in total up to 30% of net income before those payments	2026	same
Expenses incurred abroad (art. 15.18)	Capped at 1% of gross income (renta bruta), unless INR was withheld on them, then fully deductible	2026	same
Overall cap for non-employee personal services from non-IRP payees, profit shares to individuals, donations, staff benefits paid to third parties, neighbouring-farm outlays and purchases from RESIMPLE payers (art. 15, penultimate paragraph)	1% of gross income (ingreso bruto), in total	2026	same
Formation and pre-operating costs (art. 15.9)	Amortised over up to 5 years, at the taxpayer's option	2026	same
Residual value of depreciable fixed assets (art. 11)	Set by regulation; never above 20% of cost	2026	same
Transfer pricing study required (art. 39)	Related-party operations and prior-year gross income above G 10,000,000,000, or operations with low or nil tax jurisdictions whatever the size	2026	same
Related parties, capital test (art. 37)	More than 50% of voting capital, directly or indirectly; or control of management	2026	same
Dividend tax (IDU) on profits distributed to resident owners (art. 43.1)	8%	2026	same
IDU on profits distributed to non-residents, including a foreign head office (art. 43.2)	15%	2026	same
Non-resident tax (INR) rate (art. 76)	15% on the presumed net income of art. 75 (for example 100% of amounts paid to a related party or head office; 30% of non-related bank interest)	2026	same
Advance payments, IRE General and SIMPLE (Decreto 3182 art. 83 as replaced by Decreto 7402/2022 art. 1)	Four instalments, each 25% of the average IRE of the last three fiscal years; none if that average is G 10,000,000 or less	2026	https://www.dnit.gov.py/documents/47797/47809/Decreto+N%C2%B0+7402-2022.pdf/8d9f9b0b-eaf7-3b21-04db-da09578fe74f
Perception on imports by IRE General payers (Decreto 3182 art. 87)	0.4% of customs value plus customs and internal taxes before release, excluding IVA; a payment on account	2026	https://www.dnit.gov.py/documents/47797/47809/Decreto+N%C2%B0+3182-19.pdf/ee6adbdb-f9c2-7a3f-877d-96a0bbbc0a3d
Withholding by card processors on sales of IRE General and SIMPLE payers (Decreto 3182 art. 86)	1% of sales excluding IVA; a payment on account	2026	same
Withholding by State bodies on their suppliers (Decreto 3182 art. 85)	3% of the sale price, not below one minimum wage per supplier per day; a payment on account	2026	same
Withholding by slaughterhouses and cattle fairs on live cattle sales (Decreto 3182 art. 88)	0.4% of the price excluding IVA	2026	same

The SIMPLE threshold could be cut by the Executive by up to 10% a year from the sixth fiscal year of the law, never below G 1,000,000,000 (art. 140); the RESIMPLE bands and the G 10,000,000,000 transfer pricing threshold can be indexed to the BCP consumer price index once cumulative inflation passes 10% (art. 139). No decree making either change was found on the DNIT decree list on 11 November 2026, and the DNIT IRE guides still show G 2,000,000,000 and G 80,000,000.

The base

General regime (IRE RG): start from the accounting result. The base is the accounting result of the year, adjusted as the law and Decreto 3182 require (DNIT, IRE General guide). Income, costs and expenses are taken on the accrual basis (art. 7). Gross income (renta bruta) is net sales less the cost of goods or services; costs must be documented and real, and an autofactura (self-issued invoice for a purchase from an informal seller) may not exceed market price (art. 8). Gross income also includes gains on fixed assets, exchange differences, insurance recoveries, gains on shares and on the transfer of a business, rents and royalties, recovered bad debts, debts forgiven, interest (never below the BCP average deposit rate on loans the company makes, except staff advances and cooperative or bank lending) and dividends received (art. 8). Unrealised gains from biological growth, the equity-method revaluation of shareholdings and technical revaluations of fixed assets are taxed only when realised (art. 7).

Deductions (arts. 14 and 15). An expense is deductible if it is needed to earn or keep the income, is a real outlay, is documented (with the withholding made where one is due) and, if supported by an autofactura, is not above market price. The listed deductions include taxes and social charges on the business; IVA that is not creditable; general business costs; salaries where social security (IPS) contributions are paid; the aguinaldo (13th salary); non-employee personal services where the provider is an IRP or INR payer; formation costs (up to 5 years); interest, rents and royalties where the creditor is taxed on them and the price is arm's length; extraordinary and theft losses not covered by insurance; bad debts; depreciation and amortisation of purchased intangibles; donations to the State and to recognised public-benefit entities; staff travel with supporting documents. The caps in the rates table then apply.

Not deductible (art. 16). The IRE itself; fines; profits set aside for capital or reserves; amortisation of self-generated goodwill; personal spending of owners, partners or their families and drawings on account of profit; IVA that is creditable or refundable; costs of earning untaxed, exempt or foreign-source income; anything that fails the art. 14 test. Costs that serve both taxed and untaxed income are prorated by gross income (art. 17).

Depreciation (art. 11; Decreto 3182 arts. 30 and 31). Straight-line on cost less the residual value, over the useful life the regulation sets. Depreciation starts, at the taxpayer's option, in the month or the fiscal year after the asset is brought into use. A used asset takes a life no longer than a new one's. Selected lives from Decreto 3182 art. 31 (DNIT copy):

Asset (Decreto 3182 art. 31)	Useful life	Residual value
Furniture and equipment in general	5 years	10%
Tools and equipment	5 years	10%
Machinery and implements	10 years	20%
Motor vehicles in general	5 years	20%
Motorcycles, tricycles and bicycles	2 years	10%
Public passenger transport and utility vehicles	10 years	20%
Buildings and improvements, urban and rural, excluding land	30 years	20%
Silos, warehouses and sheds	20 years	20%
Buildings on third-party property	20 years, or the shorter contract term	0%
Improvements on third-party property	10 years, or the shorter contract term	0%
Purchased intangibles (brands, patents, licences)	5 years	n/a
Other assets not listed	5 years	20%

Inventories (art. 9). At production or purchase cost; LIFO is not allowed; a change of method needs DNIT authorisation.

Losses (art. 18). A tax loss can be set off against the net income of the next five fiscal years, consecutive and uninterrupted from the year after the loss, and in each year only up to 20% of that year's net income. Any part not used within the five years is lost.

SIMPLE (art. 26; Decreto 3182 arts. 76 to 79). Calendar year, accrual basis. Gross annual billing is accrued income for the year excluding IVA, and for a SIMPLE payer that must keep full accounts it includes interest on savings accounts in those accounts. Net income is the lower of real income (income less documented, directly related outgoings, with equipment and premises works deducted in full when bought) and 30% of gross billing. A loss is not carried forward. A sole-owner business in SIMPLE is not an IDU taxpayer on its profits (art. 26, last paragraph).

RESIMPLE (art. 27; Decreto 3182 art. 80). No base computation: the fixed monthly amount for the prior-year income band, paid quarterly. A RESIMPLE payer is not an IVA taxpayer (art. 27), pays no advances and suffers no IRE withholdings (Decreto 3182 art. 80). It issues the "Boleta RESIMPLE" (DNIT, RESIMPLE guide), which is deductible for a buyer only within the 1% cap. A business that files a nil annual return pays G 20,000 a month the next year (Decreto 3182 art. 80).

Moving between regimes (art. 29; Decreto 3182 art. 82). A business whose prior-year income exceeds its regime's ceiling moves up by operation of law and must update its RUC record; otherwise the DNIT changes it and fines it. A business that moved, or chose a regime, stays three fiscal years unless its income rises above that regime's ceiling. Real estate bought, sold or let by the owner of a sole-owner business in SIMPLE or RESIMPLE follows the IRP rules (arts. 30 and 31).

Advance payments (law art. 24; Decreto 3182 art. 83 as replaced by Decreto 7402/2022). IRE General and SIMPLE payers pay four advances a year, each 25% of the average IRE of the last three fiscal years, in the first, third, fifth and seventh months after the return deadline. If that average is G 10,000,000 or less, no advances are due. A business with fewer than three closed years uses the previous year's tax. The DNIT credits withholdings and perceptions suffered in the previous year against the advances, and an overpayment at year-end is set off against the next advances (DNIT, IRE General guide). After paying the first two, a taxpayer can ask to suspend the last two if they already cover the year's tax; if the final return then shows tax due, fines and surcharges run on the shortfall (Decreto 3182 art. 84).

Deadlines and filing

Portal: the DNIT's Sistema Marangatu (marangatu.set.gov.py), logged in with the Clave de Acceso Confidencial de Usuario. Payment through banks and collection points authorised by the DNIT, electronic payment or card (DNIT, IRE General guide).

1. Find the due day. Every deadline falls on a fixed day of the due month set by the last digit of the RUC, ignoring the check digit (Resolución General 38/2020, DNIT deadlines page): 0 = 7th, 1 = 9th, 2 = 11th, 3 = 13th, 4 = 15th, 5 = 17th, 6 = 19th, 7 = 21st, 8 = 23rd, 9 = 25th. A non-working day moves the deadline to the next working day. A return filed on time but paid late attracts the late-payment fine and surcharge, not the late-filing (contravención) fine (DNIT, deadlines under Ley 6380).
2. IRE General (Form 500, obligation 700). Return and payment by the due day of the fourth month after year-end: April 2027 for the 2026 year (Decreto 3182 art. 75). The return is due even if there is no taxable income (art. 74). Year-ends other than 31 December are allowed only for sugar mills and agro-industrial cooperatives (30 April) and insurers, brewers and soft-drink makers (30 June), fixed for 5 years (Decreto 3182 art. 15).
3. Financial statements (obligation 948). IRE General payers file them by the due day of the fourth month after year-end on the informative-returns calendar (0 = 8th, 1 = 10th, through 9 = 26th). For the year closed 31 December 2025 the DNIT extended this to June 2026 (Resolución General DNIT N° 50/2026). From years closed 31 December 2025 the notes must reconcile accumulated profits and detail reserves (Resolución General DNIT N° 49/2026). Taxpayers required to have an external tax audit (auditoría externa impositiva) file the audit report on the dates the DNIT sets.
4. IRE SIMPLE (Form 501, obligation 701). Return and payment by the due day of the third month: March 2027 for 2026 (Decreto 3182 art. 76).
5. IRE RESIMPLE (Form 502, obligation 702). Annual informative return within the second month (February 2027 for 2026; the DNIT guide gives 26 February and auto-generates a return at the lowest band for non-filers on 27 February). The fixed amounts are paid in March, June, September and December of the year (Decreto 3182 art. 80).
6. Advances. Obligation 735 (General) and 736 (SIMPLE). For a December year-end the General advances fall in May, July, September and November, and the SIMPLE advances in April, June, August and October (DNIT deadlines page).
7. Withholding agents confirm the DNIT's pro-forma settlement of IRE, IRP, INR and IVA withholdings within the first six calendar days of the month and pay by the 7th (Form 525, obligation 725). After filing, keep the Marangatu acknowledgement; the payment is credited to the RUC current account.
8. IDU. The company withholds IDU when profits are put at the owners' disposal: when the shareholders' meeting decides the distribution (S.A.), on the date in the by-laws or, failing that, in the fourth month after year-end (S.R.L.), and in the fourth month after year-end for a sole-owner business unless the profit is reinvested (Ley 6380 art. 44).

Penalties and interest

The penalties are in Ley N° 125/1991, Libro V, read in the copy of the law the DNIT publishes (Ley 125/91, arts. 170 to 179). The four infractions are mora, contravención, omisión de pago and defraudación (art. 170); the mora charges add to any other fine (art. 178).

• Late payment (mora, art. 171). A fine on the tax not paid on time: 4% if up to one month late, 6% up to two months, 8% up to three, 10% up to four, 12% up to five, and 14% at five months or more, counted from the day after the due date. On top, a monthly surcharge or interest computed day by day until payment, at the rate the Executive fixes every four months (capped at the bank discount rate plus 50%). A return filed on time but paid late attracts only these mora charges, not the late-filing fine (DNIT deadlines page). Late advances carry the same mora (Decreto 3182 art. 84).
• Late or missing return and other formal breaches (contravención, art. 176). A fine between G 50,000 and G 1,000,000 in the 1991 text; both limits are updated each year by decree for consumer-price inflation (art. 179), so use the decree in force.
• Underpayment without intent (omisión de pago, art. 177). Up to 50% of the tax omitted.
• Fraud (defraudación, arts. 172 to 175). One to three times the tax evaded, graded by repetition, recidivism, the size of the loss and the taxpayer's conduct; a voluntary correction before any inspection mitigates. Intent is presumed, among others, where the books contradict the return, required books are missing or more than 90 days behind, or a withholding agent pays over withheld tax more than 30 days late (arts. 173 and 174).

Cross-border points

• Foreign-source income of a resident company is taxed unless it bore a foreign income tax at 10% or more (art. 6). Foreign income tax on the same income is credited, up to the Paraguayan tax on that income, also under a tax treaty (art. 134). Costs of earning foreign-source income that is not taxed are not deductible (art. 16.7).
• Payments to non-residents. The payer withholds INR at 15% on the presumed net income of art. 75 and is jointly liable (art. 77). Examples: 30% of the gross for interest on non-related bank or multilateral loans, international transport and container hire; 70% for personal services; 100% for any amount paid to partners, a head office or related entities. The INR is final for the recipient. Expenses abroad are fully deductible for the payer only if INR was withheld; otherwise they fall under the 1% of gross income cap (art. 15.18).
• Dividends and branch profits to non-residents bear IDU at 15% (art. 43.2); the tax is final for the non-resident (art. 41). Presumed distributions include loans to owners (except by lenders within 2% of their loan book), a cash shortfall above 10% of the cash account and private use of company assets (art. 40).
• Transfer pricing (arts. 35 to 39; Decreto 4644/2020). Operations with related parties abroad, and domestic related-party operations where one side is exempt or out of scope, must be at arm's length. Operations with residents of low or nil tax jurisdictions, free-zone users and maquila companies are presumed related. A low or nil tax jurisdiction taxes the income at an effective or nominal rate below Paraguay's on similar operations and has no information-exchange agreement in force with Paraguay (Decreto 4644 art. 5 as replaced by Decreto 7402/2022). The comparable uncontrolled price method comes first; listed commodities exported are priced at the quoted market price on the shipment date (art. 38). A taxpayer above G 10,000,000,000 of prior-year gross income keeps a technical study by a professional on the DNIT register (art. 39).
• Treaties. Paraguay's double tax conventions override these rates where they apply; Ley N° 7271/2024 approved the convention with Spain. Check whether a convention is in force for the year before applying it.

Worked examples

Example 1: sole-owner business, SIMPLE or General (a decision)

Ana runs a hardware shop as an empresa unipersonal. Her 2025 accrued income, excluding IVA, was G 1,500,000,000, so she may choose SIMPLE for 2026 (the ceiling is G 2,000,000,000). In 2026 she bills G 1,500,000,000 excluding IVA. Her documented costs of goods and expenses are G 1,100,000,000, and in January she buys a machine for G 200,000,000.

• SIMPLE. Real income: 1,500,000,000 less 1,100,000,000 less the whole 200,000,000 machine = G 200,000,000. Presumed income: 30% of 1,500,000,000 = G 450,000,000. She is taxed on the lower, G 200,000,000: IRE G 20,000,000, due in March 2027.
• General. The machine is depreciated: 200,000,000 less 20% residual, over 10 years = G 16,000,000 a year. Net income 1,500,000,000 less 1,100,000,000 less 16,000,000 = G 384,000,000: IRE G 38,400,000, due in April 2027. On top, a sole-owner business in the General regime is an IDU taxpayer: profit not reinvested is treated as distributed in the fourth month and bears 8%.
• The figure that decides it is real margin against 30% of billing. In a variant year with no machine and costs of G 900,000,000, real income is G 600,000,000 but SIMPLE caps the base at G 450,000,000: IRE G 45,000,000 against G 60,000,000 in the General regime. SIMPLE never gives a higher base than the General regime for the same documented costs, because it takes the lower of the two; what it gives up is the loss carry-forward. Once chosen, she stays three years (art. 29).

name: Sole-owner business, SIMPLE against General, 2026
inputs:
  billing: 1500000000
  costs: 1100000000
  machine: 200000000
  residual_rate: 0.20
  life_years: 10
  rate: 0.10
  variant_costs: 900000000
steps:
  - simple_real: billing - costs - machine
  - simple_presumed: billing * 0.30
  - simple_base: min(simple_real, simple_presumed)
  - simple_ire: simple_base * rate
  - depreciation: machine * (1 - residual_rate) / life_years
  - general_base: billing - costs - depreciation
  - general_ire: general_base * rate
  - saving_simple: general_ire - simple_ire
  - variant_simple_base: min(billing - variant_costs, simple_presumed)
  - variant_simple_ire: variant_simple_base * rate
  - variant_general_ire: (billing - variant_costs) * rate
expected:
  simple_real: 200000000
  simple_presumed: 450000000
  simple_base: 200000000
  simple_ire: 20000000
  depreciation: 16000000
  general_base: 384000000
  general_ire: 38400000
  saving_simple: 18400000
  variant_simple_base: 450000000
  variant_simple_ire: 45000000
  variant_general_ire: 60000000

Example 2: S.A. in the General regime, related-party interest cap, loss cap and advances

Beta S.A. (calendar year) has 2026 net income of G 1,000,000,000 before deducting G 400,000,000 of arm's-length interest paid to its foreign parent. It has an unused 2023 tax loss of G 500,000,000. Its IRE for 2024 and 2025 was G 37,000,000 and G 51,000,000.

• Interest cap (art. 15.23). 30% of net income before the interest: 30% of 1,000,000,000 = G 300,000,000 deductible; G 100,000,000 is not. Net income after interest: G 700,000,000.
• Loss (art. 18). The 2023 loss is within its five years (2024 to 2028). The 2026 set-off is capped at 20% of G 700,000,000 = G 140,000,000; G 360,000,000 of the loss carries on to 2027 and 2028.
• IRE. Base G 560,000,000 at 10% = G 56,000,000, filed on Form 500 and paid in April 2027.
• INR on the interest. Interest to a related lender is not in the 30% bracket of art. 75.1(a), so the presumed net income is 100% (art. 75.6): Beta withheld 15% of G 400,000,000 = G 60,000,000 when it paid or credited the interest, whatever the deductible part.
• Advances for 2027. Average of 2024 to 2026 tax: (37,000,000 + 51,000,000 + 56,000,000) / 3 = G 48,000,000, above G 10,000,000. Four advances of G 12,000,000, in May, July, September and November 2027, less any 2026 withholdings and perceptions credited by the DNIT.

name: Beta S.A., interest cap, loss cap, INR and advances, 2026
inputs:
  income_before_interest: 1000000000
  related_interest: 400000000
  loss_bf: 500000000
  tax_2024: 37000000
  tax_2025: 51000000
  rate: 0.10
  inr_rate: 0.15
steps:
  - interest_cap: income_before_interest * 0.30
  - interest_deducted: min(related_interest, interest_cap)
  - interest_disallowed: related_interest - interest_deducted
  - net_before_loss: income_before_interest - interest_deducted
  - loss_cap: net_before_loss * 0.20
  - loss_used: min(loss_bf, loss_cap)
  - loss_cf: loss_bf - loss_used
  - base: net_before_loss - loss_used
  - ire: base * rate
  - inr_withheld: related_interest * 1.00 * inr_rate
  - average_tax: (tax_2024 + tax_2025 + ire) / 3
  - advance_each: average_tax * 0.25
expected:
  interest_cap: 300000000
  interest_deducted: 300000000
  interest_disallowed: 100000000
  net_before_loss: 700000000
  loss_cap: 140000000
  loss_used: 140000000
  loss_cf: 360000000
  base: 560000000
  ire: 56000000
  inr_withheld: 60000000
  average_tax: 48000000
  advance_each: 12000000

Ask the client first

1. Legal form (S.A., S.R.L., empresa unipersonal, cooperative, branch, non-profit) and whether the business must keep full accounts under Ley 1034/1983.
2. Gross accrued income of the previous fiscal year, excluding IVA: it fixes the regime (G 80,000,000 and G 2,000,000,000) and the transfer pricing study (G 10,000,000,000).
3. The regime it is registered in on the RUC and when it last changed (three-year lock-in), and its year-end.
4. Related parties (more than 50% or control), payments abroad and whether INR was withheld, and any counterparty in a low-tax jurisdiction, free zone or maquila.
5. Unused tax losses by year, and the IRE of the last three years (for the advances).
6. The last digit of the RUC (due day), and any incentive regime (Ley 60/1990, Ley 7548/2025, maquila) that changes the rules.

Sources

Source	URL	Read on
Ley N° 6380/2019, BACN text: Libro I Título I arts. 1 to 39 (IRE), Título II arts. 40 to 46 (IDU), Título IV arts. 71 to 79 (INR), arts. 134, 139, 140, 143	https://www.bacn.gov.py/leyes-paraguayas/9332/ley-n-6380-de-modernizacion-y-simplificacion-del-sistema-tributario-nacional	2026-11-11
Decreto N° 3182/2019 (IRE regulation), DNIT copy: Anexo arts. 15, 30, 31, 74 to 88	https://www.dnit.gov.py/documents/47797/47809/Decreto+N%C2%B0+3182-19.pdf/ee6adbdb-f9c2-7a3f-877d-96a0bbbc0a3d	2026-11-11
Decreto N° 7402/2022: new art. 83 of the Decreto 3182 Anexo (advances on the three-year average) and new art. 5 of Decreto 4644/2020 (low or nil tax jurisdictions)	https://www.dnit.gov.py/documents/47797/47809/Decreto+N%C2%B0+7402-2022.pdf/8d9f9b0b-eaf7-3b21-04db-da09578fe74f	2026-11-11
DNIT, IRE page: forms and obligations 700, 701, 702	https://www.dnit.gov.py/web/portal-institucional/ire	2026-11-11
DNIT, IRE General guide (V 08/24): base from the accounting result, Form 500, advances obligation 735, payment channels	https://www.dnit.gov.py/documents/20123/216504/IRE+General+Cartilla+27.08.24.pdf/90fc2d63-0bc0-1aae-afe3-3c57113eb5b7	2026-11-11
DNIT, IRE SIMPLE guide (V 08/24): Form 501, obligation 736	https://www.dnit.gov.py/documents/20123/216504/IRE+Simple+Cartilla+26.08.24.pdf/e1031416-9b95-d8a5-899b-27f9984a89c1	2026-11-11
DNIT, IRE RESIMPLE guide (V 08/24): Form 502, 26 February filing, Boleta RESIMPLE	https://www.dnit.gov.py/documents/20123/216504/IRE+Resimple+Cartilla+6.08.24.pdf/a0586c49-bc45-a6df-377d-562d771ddcf1	2026-11-11
DNIT, deadlines under Ley 6380 (RG 38/2020): RUC-digit calendar, advances months, informative returns, withholding settlement	https://www.dnit.gov.py/web/portal-institucional/w/vencimiento-ley-n-6380/19	2026-11-11
Resolución General DNIT N° 50/2026: financial statements for years closed 31/12/2025 extended to June 2026	https://www.dnit.gov.py/documents/20123/2664257/Resoluci%C3%B3n+General+DNIT+N%C2%B0+50_26.pdf/07746a1d-67a4-d2e2-fe0a-a98ab3b3a723	2026-11-11
Resolución General DNIT N° 49/2026: notes on profits and reserves, obligation 948, from years closed 31/12/2025	https://www.dnit.gov.py/documents/20123/2664257/Resolucion+General+DNIT_49_IDU__26000047612E_firmado.pdf/72c96bdb-8d92-c9e8-f53a-f468b04a1a71	2026-11-11
DNIT, list of tax laws (checked for laws amending Ley 6380: Ley 7067/2023 on art. 100 only; Leyes 7547 and 7548 of 2025 read for their references to Ley 6380)	https://www.dnit.gov.py/web/portal-institucional/leyes	2026-11-11
DNIT, list of decrees (checked for decrees changing the art. 26, 27 and 39 amounts: none found)	https://www.dnit.gov.py/web/portal-institucional/decretos	2026-11-11
Ley N° 7548/2025, investment incentive regime, art. 4 (IDU and INR exemptions for projects of at least USD 13,000,000)	https://www.dnit.gov.py/documents/20123/277628/LEY+7548.2025.pdf/adf4eef6-276f-0a9e-5091-9c940966ee04	2026-11-11
Ley N° 125/1991, DNIT copy of the 1991 text (scanned; arts. 157 to 180 read by OCR): mora, contravención, omisión de pago, defraudación	https://www.dnit.gov.py/documents/47797/47809/P+-+Ley+N%C2%BA+125-91.pdf/63cf3ff2-2b45-5920-cfc0-e562ff41ced9	2026-11-11

Not yet confirmed: the useful life of computer equipment in Decreto 3182 art. 31.1.b.iii (the DNIT copy is stamped over that line); whether any decree after Decreto 7402/2022 amends the Anexo of Decreto 3182 (the DNIT decree list shows Decretos 3276, 3367, 3725 and 3768 of 2020 amending it, not read here); the current minimum wage used for the State-supplier withholding floor; the entry into force of the Paraguay-Spain convention approved by Ley 7271/2024 and the list of other conventions in force; the Marangatu box numbers of Forms 500, 501 and 502; whether the BACN text of Ley 6380 is a consolidated text (it is the 2019 text; DNIT's law list shows no IRE amendment). The current monthly mora surcharge rate and the current contravención limits after the art. 179 indexation decrees; whether Ley 2421/2004 or later laws changed arts. 171 to 177 (the DNIT copy is the 1991 text).